Emissions report verification

Verification process

Aircraft operators submit the completed emissions report to their verifier, who will then assess whether it complies with statutory guidelines and whether it is based on the situation described in the monitoring plan approved by the NEa. If so, the aircraft operator will receive a declaration of approval from the verifier. The declaration will be put into a verification report along with the verifier's findings, which may result in the aircraft operator having to submit an improvement report (not part of the Year-end closing, and not due until later in the year).

A support document (Verification Guidance for Aviation) has been drawn up for aircraft operators, verifiers and accreditation bodies. This document contains a user-friendly interpretation of the verification requirements of the EU ETS Directive and the Accreditation and Verification Regulation.

Verification based on current monitoring plan

Verification is based on the current monitoring plan (MP), which is the MP approved by the NEa. Aircraft operators must promptly incorporate any modifications into their MP and submit them to the NEa for approval.

Remote verification

A verifier may in some cases access databases and procedures remotely from the verifier’s desk top. For example a verifier can carry out the main cross-check with EUROCONTROL data on flights to assess the completeness of flights instead of visiting the different aircraft operator locations, aerodromes and aircraft to assess the data. This is only allowed if the verifier:  

• visits the head office; and
• the verifier’s risk analysis shows that such remote access is justified.

For small emitters an on-site visit is waived if the aircraft operator makes use of the small emitters tool and the verifier has access to the Eurocontrol flight details.

Virtual site visits

Due to the COVID-19 pandemic, Article 34a was added to commission regulation 2020/2084 on virtual site visits. Article 34a makes it possible for verifiers to carry out virtual site visits in the case of force majeure. The term force majeure is understood to mean a serious, unusual and unforeseeable circumstances beyond the control of the aircraft operator. Under such circumstances the verifier may decide to carry out virtual verification. Virtual verification must be approved in advance. In the case that the verifier must carry out a large number of virtual verifications, it is the aircraft operator that must notify the NEa prior to the verifier carrying out the virtual verification.

In 2020 and 2021 the NEa issued a general waiver for onsite verifications if the notification form of virtual visit was submitted by airline operators together with the emissions report. For 2022, no general waiver will be granted. This means that if there are extraordinary and exceptional situations, prior approval is required for the adoption of a virtual site visit. Please note this will only be granted in extraordinary and exceptional situations. To receive a copy of the request form virtual verification, please sent an e-mail to: reporting@emissieautoriteit.nl with this request.

Verification exemption for simplified reporting using the ETS support facility

If an aircraft operator eligible for simplified reporting and verification, then it is possible to make use of the automatically generated emissions report provided by the Eurocontrol ETS Support Facility. In this case verification of the emissions report will be performed by the NEa under the condition that the report has not been altered. The aircraft operator does therefore not need to submit a verification report with the emissions report.

However, for aircraft operators making use of this relaxation with obligations under CORSIA, flights between third countries must still be verified.

An airline operator is eligible for simplified reporting and verification if it has:

• Less than 243 flights for 3 consecutive 4 month periods, or

• Annual CO2 emissions are less than 25.000 tons CO2 under the ‘full scope’, or less than 3000 tons CO2 under the ‘reduced scope’.

Separate verification required for EU ETS and CORSIA

Operators with reporting obligations towards the NEa for CORSIA submit a single combined emissions report but must submit separate verification reports for the EU-ETS and CORSIA data sets. For more information on reporting for CORSIA please refer to our website.